Public Comment

Colin Bishopp
Executive Director, PACENation
colin@pacenation.org
202.550.7570

July 10, 2020
Kathleen L. Kraninger, Director
Consumer Financial Protection Bureau
1700 G Street NW
Washington, DC 20552
Re: Account Level Data Collection from PACE Program Administrators
Dear Director Kraninger:
I am writing in response to the Consumer Financial Protection Bureau’s (“Bureau”) request for comment
regarding a Generic Information Collection titled, “Account Level Data Collection from PACE Program
Administrators.” We appreciate the opportunity to comment on the Bureau’s data collection process.
We offer three comments for your consideration:
1. The Bureau’s Request for Information (“RFI”) must be structured to protect homeowner data
privacy, including personally identifiable information ("PII"). Examples include names,
addresses, Social Security numbers and assessor's parcel numbers and equivalents. The RFI
should provide program administrators and governmental entities, which are the subject of data
requests, with the means to ensure compliance with all federal and state privacy laws and should
provide indemnification to private entities for potential data security breaches not caused by such
entities. Additionally, to protect confidential customer financial data and PII, the data request
should request the minimum amount of such PII necessary to achieve the data analysis goals and
use encryption wherever possible.
2. Any third-party access to the data (e.g., by Bureau vendors) must be done in a manner that
removes all PII and protects homeowners. Any use of credit reports should be structured to avoid
being counted as a "hard" or "soft" credit pull, which could negatively impact consumer credit
scores.
3. The Bureau’s rulemaking process for residential PACE financing should focus on account level
data collected prior to the emergence of the COVID-19 pandemic. The rulemaking should be
based on project data under normal circumstances as opposed to project data that has been
influenced by a once-in-a-century outlying event like a global pandemic.
Thank you again for the opportunity to comment on the Bureau’s data collection process.
Sincerely,

Colin Bishopp
Executive Director